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Friction Division Products

All POLREP's for this site Friction Division Products
Lawrence Township (Trenton), NJ - EPA Region II
POLREP #35 - Temporary Suspension of Removal Activities
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On-Scene Coordinator - Paul L. Kahn & Eric M. Daly 8/6/2007
Time-Critical - Removal Action Pollution Report (POLREP) #35
Start Date: 6/26/2006
Pollution Report (POLREP) #35
Site Description
This Site, a defunct automotive brake pad manufacturer, was brought to the attention of EPA by the NJDEP for a possible referral for a CERCLA removal action.  An inspection by EPA OSCs and a DEP responder on 12/23/05 revealed the following hazardous materials/wastes were abandoned at the site: tons of asbestos material, tons of elemental sulphur, 1,000+ drums of mostly unknown materials or materials that do not match the label description, hundreds of smaller containers, acids, flammable liquids, iron and aluminum powders, flammable solids, waste oil, solvents, and other contaminants or pollutants.  The Site is semi-controlled, with most doors being locked but numerous open windows or sections of sheet-metal walls missing. A maintenance man is on-site for a few hours Mon-Fri.  

During June, 2006, the OSC observed that employees of the RP, Friction Division Products, were entering the Site and loading contaminated drums and debris in a roll-off from Building #7. In the process of removing the contaminated debris they spilled powdered chemicals from broken bags on a pallet. EPA brought this to the attention of the property owners.  With EPA management authorization and the owner's permission EPA initiated security guard service as of June 15, 2006 to prevent access by the RP and other unauthorized persons.  Security guard service was discontinued on June 26, 2006, when the RP agreed to not enter the Site unless EPA was present.


Current Activities
ERRS completed decommissioning all baghouses as of 7/26/07. ERRS  cleaned about 1,000 linear feet (see cover image) of ACM-contaminated duct work.  To date, a total of 80 cubic yards of ACM, totaling more than 8 tons of Chrysotile-form asbestos, been bulked.  ERRS bulked more than 24 tons of metal that comprised the baghouse shells and duct-work for recycling.  ERRS began to disassemble the internal PVC frame in the negative air pressure enclosure in Q3 where the baghouses were decommissioned.  The sectionalized, tublar frame will be shipped to EPA Edison for storage in Building 212.

On 8/3 and8/6 ERRS shipped 227 55-gallon and 85-gallon overpacked drums of waste chemicals for disposal.

Removal activities have been suspended for approx. two weeks pending firm date to ship the tons of ACM for disposal.  The few remaining minor removal activities will be completed when crew is remobed for final T & D.





Planned Removal Actions
Complete bulking ACM from the processing building Q3, and shovel ACM from piles located around the Site.  Complete bulking scrap metal for recycling.

Clean Q3 to remove any residual ACM.

Demobe Site until shipping date for ACM is received.

Test ACM processing/decon water for asbestos and make plans for disposal.


Next Steps
Remobe crew to complete removal action.

Key Issues
None.